Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupport
Contact Us
Search
Close

CFPB Reopens Its Open Banking Rule for Comment

By Noah Gillespie, Timothy A. Butler, Lisa M. Lanham, Shane Foster, Matthew White & Tessa Cierny on September 22, 2025
Email this postTweet this postLike this postShare this post on LinkedIn
Corporate_Proposal

Various stakeholders, including financial institutions and technology companies, are involved in developing open banking frameworks and the technical standards for financial data sharing. These developments may enable new insights, products, and services based on a more comprehensive view of consumers’ financial information. The Dodd-Frank Act sought to give consumers an active role in open banking by requiring financial institutions to share consumer financial data at the consumer’s request, subject to CFPB rulemaking (the Open Banking Rule). Former CFPB Director Kathy Kraninger launched a rulemaking process in 2016 to implement a long-dormant provision of the Dodd-Frank Act, resulting in the 2024 Final Rule. Now, the CFPB is seeking comment on whether to revisit and potentially reshape the 2024 Final Rule based on the evidence it collects and its new policy priorities.1

Link to Click here to read the full GT Alert. Click here to read the full GT Alert.


1 Personal Financial Data Rights Reconsideration, 90 Fed. Reg. 40986 (Aug. 22, 2025).

Photo of Noah Gillespie Noah Gillespie

Noah N. Gillespie is a thought leader who helps financial institutions, payment processors, money services businesses, and fintech companies bring innovative consumer financial products and services to market. He advises clients on federal and state consumer compliance, licensing, and regulatory requirements across the…

Noah N. Gillespie is a thought leader who helps financial institutions, payment processors, money services businesses, and fintech companies bring innovative consumer financial products and services to market. He advises clients on federal and state consumer compliance, licensing, and regulatory requirements across the banking, payments, and digital finance sectors. He provides practical, focused advice that translates complex statutory and regulatory requirements into actionable operational direction.

Read more about Noah GillespieEmailNoah's Linkedin Profile
Show more Show less
Photo of Timothy A. Butler Timothy A. Butler

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia…

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia Attorney General’s Office, Tim has led the defense of dozens of government investigations and enforcement actions brought by the FTC, the Consumer Financial Protection Bureau (CFPB), and the various state attorneys general. Tim also regularly defends clients in bet-the-company lawsuits, including complex business disputes and consumer class actions alleging privacy, false advertising, and unfair or deceptive business practice claims.

Tim is an experienced guide for companies struggling with regulatory complexity. He offers clear advice that helps his clients meet the demands of the ever-growing set of laws and regulations governing data privacy and cybersecurity, advertising and marketing practices, and consumer financial products and services. Clients rely on Tim’s business-minded and practical strategies to address their most difficult regulatory compliance challenges.

A graduate of the University of Chicago and Stanford Law School, Tim is a prolific author and regularly speaks to industry and trade groups about the evolving privacy landscape, about cutting-edge issues affecting payments and fintech companies, and about developments at the FTC, the CFPB, and within the state attorneys general community.

Read more about Timothy A. ButlerEmailTimothy's Linkedin Profile
Show more Show less
Photo of Lisa M. Lanham Lisa M. Lanham

Lisa M. Lanham focuses her practice on fintech and payments solutions within the financial services sector. Her role encompasses work with a diverse range of clients, including residential and commercial mortgage brokers, lenders, servicers, loan fulfilment providers, student, consumer, and solar loan lenders

…

Lisa M. Lanham focuses her practice on fintech and payments solutions within the financial services sector. Her role encompasses work with a diverse range of clients, including residential and commercial mortgage brokers, lenders, servicers, loan fulfilment providers, student, consumer, and solar loan lenders and servicers, marketplace lenders, and entities offering retail installment contracts for consumer goods. Moreover, she advises investors engaged in secondary market activities. Lisa also extends her support to emerging fintech firms, helping them to comply with necessary state licensing requirements and develop products in these realms while keeping regulatory demands in check.

A large part of Lisa’s role involves working closely with regulators such as the New York State Department of Financial Services to facilitate her clients’ pursuit of necessary business licenses and approvals. This not only includes completing audits and examinations but also covering intricate disclosure issues and reporting changes of ownership, executive management, and qualifying individuals. In addition to these tasks, Lisa was involved in the development of the Nationwide Multistate Licensing System & Registry (NMLS) 2.0 system. She handles virtually all aspects of the NMLS, including submissions and amendments of company application forms and electronic surety bonds.

Her contributions extend to representation and regulatory counsel in areas such as structured finance, securitization, secondary market transactions, licensing matters in mergers and acquisitions transactions, regulatory agency coordination for large-scale multistate transactions, and various financial service operations. In addressing state licensing matters, Lisa has contributed to notable projects such as assisting international crypto exchanges enter into the U.S. market by setting up compliant subsidiaries.

Lisa’s work also includes the reporting of material licensing changes, providing technical reviews, analyzing proposed business models in the context of regulatory compliance issues, assisting with the development of policies and procedures for regulatory compliance concerns, negotiating findings before examination report finalization, and managing international licensing issues amidst dynamic regulatory environment.

Read more about Lisa M. LanhamEmailLisa M.'s Linkedin Profile
Show more Show less
Photo of Shane Foster Shane Foster

Shane Foster is a shareholder with deep financial regulatory experience in areas such as banking, money transmission, lending, and fintech, among others. Serving in a high-level capacity as Chief Deputy Director at the Arizona Department of Insurance and Financial Institutions (DIFI), he oversaw

…

Shane Foster is a shareholder with deep financial regulatory experience in areas such as banking, money transmission, lending, and fintech, among others. Serving in a high-level capacity as Chief Deputy Director at the Arizona Department of Insurance and Financial Institutions (DIFI), he oversaw the agency’s enforcement, depository, non-depository, consumer affairs, and insurance market conduct divisions.

As a former regulator, Shane has a thorough understanding of regulatory issues affecting the financial services sector and has deep experience in licensing, compliance, investigatory, and enforcement matters. From advising on chartering de novo depository institutions, merger activity, solvency and deposit insurance issues, to ensuring compliance with consumer protection and safety and soundness regulations, he provides financial institutions with insights to navigate complex issues. Additionally, his experience encompasses various consumer finance segments such as mortgage, vehicle title, and unsecured lending. Shane also led the efforts in drafting and implementing Arizona’s money transmission law (i.e., CSBS Model Money Transmission Modernization Act), which substantive provisions can be found in many states throughout the country.

Shane’s practice extends to the use of new technologies and innovation in the financial services sector. He served a prominent role in the administration of the nation’s first state regulatory sandbox, bolstering his deep understanding of the use of novel products and services in the ever evolving fintech sector (e.g., blockchain technology, digital payments, APIs, artificial intelligence, and mobile applications, among others). Shane also stays at the forefront of law and policy developments regarding digital assets. Whether dealing with transmission and custody issues or monitoring recent guidelines by federal agencies concerning crypto-related activities and stablecoins, Shane stays abreast of developments to advise clients on innovative legal strategies.

Shane has worked closely with state regulators through active involvement in the Conference of State Bank Supervisors (CSBS), National Association of Insurance Commissioners (NAIC), and the National Association of Attorneys General (NAAG), serving as a key participant in numerous multistate initiatives, including serving on the coordinating committee with the Consumer Financial Protection Bureau (CFPB) and on data privacy working groups, among others. Simultaneously, his background in government relations has given him many opportunities to interface with various federal agencies and draft comments on proposed federal policies.

Shane Foster is a sought-after speaker on a variety of topics concerning financial regulation, having spoken on numerous panels at industry and government-related events.

Read more about Shane FosterEmail
Show more Show less
Photo of Matthew White Matthew White

Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.

Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the…

Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.

Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Truth in Lending Act, and their respective implementing regulations (Regulations E, V, P, and Z). Adept with the Consumer Financial Protection Bureau’s (CFPB) Prepaid Rule, Matt has provided guidance regarding prepaid cards and related compliance.

Matt has also aided clients in developing regulatory compliant products and functionalities, including an earned wage access program, reimbursement prepaid card programs, new merchant cash advance products, and tokenized payment capabilities. In connection with products on which Matt advises, he has also negotiated high-stakes technology sales agreements involving complex regulatory issues, including compliance with data privacy laws, financial regulations, and card network rules.

Beyond helping clients strategize for regulatory complexity, Matt also helps clients navigate government investigations and enforcement actions brought by the Federal Trade Commission (FTC), CFPB, and state attorneys general.

Read more about Matthew WhiteEmailMatthew's Linkedin Profile
Show more Show less
Photo of Tessa Cierny Tessa Cierny

Tessa Cierny advises companies on financial technology and data privacy issues. She has experience counseling companies on state and federal regulatory compliance, including existing and emerging privacy laws, such as the E.U.’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act

…

Tessa Cierny advises companies on financial technology and data privacy issues. She has experience counseling companies on state and federal regulatory compliance, including existing and emerging privacy laws, such as the E.U.’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), as well as financial and banking regulations, such as the CFPB’s Section 1071 Small Business Lending Rule (Regulation B). In addition, she assists clients in defending business disputes and data breach litigation.

Prior to joining Greenberg Traurig, she served as global records manager for WestRock, where she developed and implemented email and data retention policies for global data privacy regulation compliance. In this role, she also advised on data privacy concerns related to data retention, data loss prevention, and data governance.

Read more about Tessa CiernyEmailTessa L.'s Linkedin Profile
Show more Show less
  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Financial Services Observer
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
  • About LexBlog
  • The Field We Built
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo